The US Government just placed Australia and the United Kingdom (UK) in nearly the same position as Canada for dual-use exports under the Export Administration Regulations (EAR) and is poised to go even further with a proposed...more
5/8/2024
/ Australia ,
Commerce Control List ,
Corporate Counsel ,
Directorate of Defense Trade Controls (DDTC) ,
Dual Use Goods ,
Export Administration Regulations (EAR) ,
Exports ,
ITAR ,
NISPOM ,
Popular ,
Proposed Regulation ,
UK
License Exception MED, published by the US Department of Commerce’s Bureau of Industry and Security (BIS) on April 25, authorizes the export, reexport, or in-country transfer of EAR99 “medical devices” to non-military...more
Two years after the start of Russia’s war in Ukraine and one week after the death of opposition politician and anticorruption activist Aleksey Navalny, the US government announced a new raft of sanctions and export controls...more
On October 28, 2022, the US Department of Commerce, Bureau of Industry (BIS) issued FAQs on the new semiconductor regulations. The FAQs are short and relatively clear (thank you!) even if they were released on a Friday...more
Watch Out, More Things Are Luxury Than You Think!
On March 11, 2022, the President issued Executive Order 14068 (EO 14068) Prohibiting Certain Imports, Exports, and New Investment with Respect to Continued Russian...more
3/15/2022
/ Belarus ,
Economic Sanctions ,
Energy Sector ,
EU ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Exports ,
Imports ,
Most-Favored Nations ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trade Restrictions ,
U.S. Treasury ,
Ukraine
In this WorldSmart podcast, International Trade & Investment Practice Leader Kay Georgi discusses the current and future issues of export controls and economic sanctions, with International Group Co-Chairs Hunter Carter and...more
11/24/2021
/ Automotive Industry ,
Coronavirus/COVID-19 ,
Country of Origin ,
Economic Sanctions ,
Export Controls ,
Exports ,
Free Trade Agreements ,
Importers ,
International Criminal Court ,
International Travel ,
Personal Protective Equipment ,
Tariffs ,
Trade Policy ,
Trade Relations ,
Trade Restrictions ,
Trade Wars ,
United States-Mexico-Canada Agreement (USMCA) ,
Virus Testing ,
WTO
Companies should be prepared to conduct additional due diligence for any transactions involving entities in the countries enumerated in this rule.
In an interim rule published on, January 15, 2020, the Department of...more
3/17/2021
/ Biological-Weapons ,
Bureau of Industry and Security (BIS) ,
Chemical Weapons ,
China ,
Cuba ,
Due Diligence ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Entities ,
Interim Final Rules (IFR) ,
Iran ,
North Korea ,
Nuclear Weapons ,
Russia ,
Syria ,
Trump Administration ,
U.S. Commerce Department ,
Venezuela
The US Department of Commerce, Bureau of Industry and Security (BIS) issued a final rule amending the license review policy for items on the Commerce Control List that are controlled for national security (NS) reasons and are...more
Target areas are telecom, information security, and sensor items that can be used for censorship, surveillance, detention, and use of force.
On October 6, 2020, the US Department of Commerce, Bureau of Industry and...more
BIS will be looking at items that are controlled only for anti-terrorism, crime control, short supply, United Nations embargoes, or designated as EAR99 in establishing new Foundational Technologies Controls.
Two years...more
8/28/2020
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Embargo ,
Export Control Reform Act (ECRA) ,
Exports ,
FIRRMA ,
Interim Final Rules (IFR) ,
Military End Use ,
National Security ,
Rulemaking Process ,
United Nations
There is a risk that garments made from cotton produced by XPCC could be subject to a Customs and Border Protection withhold release orders.
Fashion and luxury goods companies need to be concerned about the recent...more
8/26/2020
/ China ,
Customs and Border Protection ,
Economic Sanctions ,
Entity List ,
Exports ,
Forced Labor ,
Imports ,
Retailers ,
Supply Chain ,
U.S. Commerce Department ,
U.S. Treasury
On August 17, 2020, the Department of Commerce, Bureau of Industry and Security (BIS) issued a final rule (the Final Rule) (1) adding additional Huawei non-US affiliates to the Entity List, (2) confirming the expiration of...more
On Monday, June 29, the Departments of Commerce and State announced that they were following through with changes to treat Hong Kong like China for exports of military and dual-use goods.
The Department of Commerce announced...more
On Friday, May 15, 2020, the Department of Commerce and the Bureau of Industry and Security (BIS) revised an arcane export control rule that imposes US export controls on foreign-origin products (hardware, software, and...more
As the COVID-19 pandemic has expanded exponentially, so too has the demand by hospitals and other healthcare providers for masks and other medical personal protective equipment (PPE) to protect doctors, nurses, and other...more
5/14/2020
/ Azerbaijan ,
Cambodia ,
Coronavirus/COVID-19 ,
Export Bans ,
Export Controls ,
Exports ,
Medical Supplies ,
Personal Protective Equipment ,
Public Health Emergency ,
Rescission ,
Sri Lanka
Rumors have circulated through the export community for months, and the Bureau of Industry and Security (BIS) has finally acted. In a final rule published April 28, 2020, BIS is removing License Exception Civil End-Users...more
In yet another action on April 28, 2020, the Bureau of Industry and Security (BIS) issued a final rule imposing stricter license requirements on a wide range of exports, reexports and transfers to China, Russia, or Venezuela...more
On April 28, the Bureau of Industry and Security (BIS) issued a proposed rule that would revise License Exception Additional Permissive Re-Exports (APR) to remove a current provision that allows for reexports of items subject...more
As the COVID-19 pandemic has expanded exponentially, so too has the demand by hospitals and other healthcare providers for masks and other medical personal protective equipment (PPE) to protect doctors, nurses, and other...more
The Federal Emergency Management Agency has left many important questions blowing in the wind as a result of a Notification of Exemptions action published for public inspection on Friday, April 17, 2020. The final action will...more
As the COVID-19 pandemic has expanded exponentially, so too has the demand by hospitals and other healthcare providers for masks and other medical personal protective equipment (PPE) to protect doctors, nurses, and other...more
The Federal Emergency Management Agency (FEMA) has exercised its delegated authority under the Defense Production Act (DPA) to issue a temporary final rule (Prioritization and Allocation of Certain Scarce or Threatened Health...more
As the COVID-19 pandemic has expanded exponentially, so too has the demand by hospitals and other healthcare providers for masks and other medical personal protective equipment (PPE) to protect doctors, nurses, and other...more
On January 15, 2020, President Trump and Chinese Vice Premier Liu Hu signed the long-awaited US-China Trade Agreement after nearly two years of a trade war that has resulted in crippling tariffs on almost $500 billion worth...more
1/24/2020
/ China ,
Customs and Border Protection ,
Exports ,
Imports ,
Section 301 ,
Supply Chain ,
Tariffs ,
Trade Agreements ,
Trade Relations ,
Trade Wars ,
Trump Administration ,
US Trade Policies
Third-country companies doing business with Iran’s construction, mining, manufacturing, or textiles sectors are now at increased risk of being sanctioned.
On Friday, January 10, President Trump issued Executive Order (EO)...more
1/16/2020
/ Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Exports ,
Foreign Policy ,
Foreign Relations ,
Goods or Services ,
Imports ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trump Administration